Paved

1. WHAT INFORMATION DO WE COLLECT?

Personal information we collect

In Short: We collect personal information that you provide to us and that we receive from Publishers about their Newsletter Subscribers.

We collect personal information that you voluntarily provide to us when you: (a) visit our website; (b) register for an account as an Advertiser or Publisher; (c) participate in activities related to our marketplace platform; or (d) contact us. We also receive personal information about Newsletter Subscribers from Publishers who use our platform. Publishers are responsible for obtaining appropriate consent from their Newsletter Subscribers before sharing such information with us.

Personal information provided by you. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and whether you are a Visitor, Publisher, Advertiser, or Newsletter Subscriber. The personal information we collect may include the following:

• names
• email addresses
• usernames
• passwords
• contact preferences
• company and business information
• mailing addresses
• telephone numbers
• payment information
• professional information

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — may be automatically collected when you interact with our Services and/or when you interact with an email sent to you by one of our Publishers. We do not collect precise geolocation data.

We automatically collect certain information when you visit, use, or navigate the Services, or interact with an email you have received from a Publisher of ours. This information does not reveal your specific identity, but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, for our internal analytics, marketplace functionality, and reporting purposes.

The information we collect includes:

• Log and Usage Data. We automatically collect service-related, diagnostic, and performance information when you access our Services or interact with emails from our Publishers. This log data may include your IP address, device information, browser type, and activity data (such as the date/time stamps, pages viewed, searches, and features used).
• Device Data. We collect device data such as information about your device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Publisher and Advertiser Activity Data. When you use our marketplace platform as a Publisher or Advertiser, we automatically collect information about your interactions with the platform, including campaign creation, publisher searches, bid submissions, communication patterns, and platform usage analytics to improve our matching algorithms and marketplace functionality.
• Newsletter Subscriber Enhancement. When Publishers use our marketplace platform, we receive information of their Newsletter Subscribers, which may include demographic information, geographic location, interests, or other subscriber profile data that Publishers choose to share with us. Publishers are responsible for obtaining appropriate consent from their Newsletter Subscribers before sharing such information with us, in accordance with the Publisher's own privacy policy. We may supplement this data with information from third-party sources to identify relevant audiences for Advertisers’ sponsored content campaigns.

Information collected from other sources

In Short: We may collect personal information from public databases, marketing partners, and other third-party sources. We also collect personal information from Publishers about their Newsletter Subscribers and may supplement this information using third-party providers.

We obtain personal information from the following sources:

• Publishers: When Publishers use our marketplace platform, they provide us with personal information about their Newsletter Subscribers, including email addresses, demographic information, geographic location, interests, and other subscriber data that allows us to identify relevant audiences for Advertisers’ sponsored content campaigns.
• Third-Party Enhancement Services: We use third-party services to supplement Newsletter Subscriber data with demographic and interest data.
• Public Databases and Data Providers: We may obtain information from public databases, commercial data providers, data analytics services, and other third-party sources to enhance our ability to provide relevant marketing services and improve our marketplace matching capabilities.

We combine information from these sources to help match Advertiser campaigns with newsletters whose audiences may find them relevant.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information: (a) to operate our marketplace platform connecting Publishers and Advertisers; (b) to supplement Newsletter Subscriber data for advertising targeting; (c) to provide, improve, and administer our Services; (d) to communicate with you; (e) for security and fraud prevention; and (f) to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on whether you are a Visitor, Publisher, Advertiser, or Newsletter Subscriber, including:

• To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your Publisher or Advertiser account, as well as keep your account in working order.
• To operate our marketplace platform. We process Publisher information to create searchable profiles of email marketing services, and we process Advertiser information to facilitate campaign purchases and matching with relevant Publishers.
• To supplement Newsletter Subscriber data for advertising targeting. We process personal information received from Publishers about their Newsletter Subscribers by using third-party enhancement services to append additional demographic and interest data to help match Advertiser campaigns with newsletters whose audiences may find them relevant.
• To respond to user inquiries/offer support. We may process your information to respond to your inquiries and solve any potential issues you might have with our Services.
• To send administrative information. We may process your information to send you details about our Services, changes to our terms and policies, campaign notifications, and other marketplace-related information.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Services.
• To create audience insights and analytics. We process Newsletter Subscriber data and campaign performance information to create aggregated audience insights, demographic reports, and campaign analytics for Publishers and Advertisers.
• To process payments and transactions. We process commercial information including payment details, transaction history, and financial information to facilitate campaign purchases and Publisher payments through our marketplace platform.
• To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share personal information with Publishers and Advertisers to operate our marketplace platform, with third-party data enhancement services to improve targeting, and in other specific situations described in this section.

We may need to share your personal information in the following situations:

• Subsidiaries and Affiliates. We may share your information with our affiliates. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with business partners who work with us to operate our marketplace platform. This includes:
  • Publishers who use our platform to offer email marketing and sponsored content services; and
  • Advertisers who use our platform to purchase marketing campaigns.
• Publishers and Advertisers on our platform. We facilitate data sharing between Publishers and Advertisers to enable sponsored content campaigns. Publishers may share aggregated, anonymized data about their Newsletter Subscribers to help identify relevant audiences. Advertisers may access campaign performance data and audience insights related to their campaigns.
• Third-Party Data Enhancement Services. We may share Newsletter Subscriber information received from Publishers with third-party data services who append additional demographic and interest data to help match relevant sponsored content with Publisher newsletters.
• Service Providers. Carefully selected companies that provide services for or on behalf of us, such as companies that help us with cloud infrastructure, customer care activities, chat functionality, advertising (including personalized advertising on our websites, third-party websites, online platforms, and social media platforms), conducting customer satisfaction surveys, billing, or that sends emails on our behalf. These providers are also committed to protecting your information.
• Other Parties When Required by Law. For example, it may be necessary by law, legal process, or court order from governmental authorities to disclose your information. They may also seek your information from us for the purposes of law enforcement, national security, anti-terrorism, or other issues that are related to public security.
• Other Parties in Connection with Corporate Transactions. We may disclose your information to a third party as part of a merger or transfer, acquisition or sale, or in the event of bankruptcy.
• Other Parties with Your Consent or at Your Direction. In addition to the disclosures described in this Privacy Policy, we share information about you with third parties when you separately consent to or request such sharing.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We use cookies and other tracking technologies to collect and store your information for marketplace functionality, advertising targeting, and analytics. We may also share cookie data with third-party data enhancement services and advertising partners.

We use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. These online tracking technologies help us:

• Maintain the security of our Services and your Publisher or Advertiser account
• Prevent crashes, fix bugs, and save your preferences
• Assist with basic site functions and marketplace operations
• Track Publisher and Advertiser interactions for campaign matching

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to:

• Help manage and display advertisements
• Tailor content displayed based on your interactions with our Services
• Create audience profiles for sponsored content targeting
• Track campaign performance and Publisher-Advertiser matching effectiveness

To the extent these online tracking technologies are deemed to be a “sale”/”sharing” (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section “DO UNITED STATES RESIDENTS HAVE ADDITIONAL PRIVACY RIGHTS?” You may also exercise your right to delete your personal information by visiting Your Privacy Choices.

Google Analytics

We may share your information with Google Analytics to track and analyze the use of the Services, including Publisher and Advertiser marketplace interactions, campaign performance metrics, and audience engagement data. To opt out of being tracked by Google Analytics across the Services, visit https://tools.google.com/dlpage/gaoptout. For more information on the privacy practices of Google, please visit the Google Privacy & Terms page.

5. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?

In Short: We may transfer, store, and process your information in countries other than your own.

We use cloud-based servers located in various regions around the world, including the United States. If you are accessing our Services from outside, please be aware that your information may be transferred to, stored by, and processed by us in our facilities and in the facilities of the third parties with whom we may share your personal information (see “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?” above), in other countries. Please note that the privacy laws and other laws of countries to which your information may be transferred might not be as comprehensive as those in your country. We take appropriate measures, in compliance with applicable law, to ensure that your personal information remains protected. For transfers from the European Economic Area, United Kingdom, or Switzerland, we rely on appropriate safeguards, such as Standard Contractual Clauses or other lawful transfer mechanisms, as required by applicable law.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 13 years of age. Users under 18 are not permitted to create Publisher or Advertiser accounts.

• Visitors: Visitors of any age may browse our website. We do not knowingly collect, solicit data from, or market to children under 13 years of age who visit our website, nor do we knowingly sell such information.
• Account Creation Restrictions: Users under 18 years of age are not permitted to create Publisher or Advertiser accounts on our marketplace platform. By creating a Publisher or Advertiser account, you represent that you are at least 18 years of age (or the age of majority in your jurisdiction, whichever is greater).
• Newsletter Subscribers: We may indirectly receive personal information about minors through Publishers who share Newsletter Subscriber data with us. Publishers are responsible for obtaining appropriate parental consent before including minors under 13 in data shared with us and for complying with applicable children’s privacy laws.

If you become aware of any data we may have collected from children under age 13, please contact us at privacy@paved.com. If we become aware that we have received personal information about a child under 13 without verified parental consent, we will promptly delete such information from our systems.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: We will consider and act upon any privacy request in accordance with applicable privacy laws. Publishers, Advertisers, Newsletter Subscribers, and Visitors all have privacy rights. Based on the applicable laws of your state of residence in the United States, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent from our processing of your personal information. These rights may be limited in some circumstances by applicable law.

• Platform User Accounts (Publishers and Advertisers): If you are a Publisher or Advertiser, you may request to access, correct, or delete the personal information in your Publisher or Advertiser account by contacting us using the contact information provided. We may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.
• Newsletter Subscriber Rights: If you are a Newsletter Subscriber whose information we process through Publishers, you have the right to access, correct, or delete your information even though you don't have a direct account with us. You can exercise these rights by contacting us directly or through the Publisher who shared your information with us, or by exercising your rights by visiting Your Privacy Choices.
• Withdrawing Your Consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?" below or updating your preferences. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
• Cookies and Similar Technologies: Most internet browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. Learn more about our use of cookies and similar technologies in the section "DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?"

10. DO UNITED STATES RESIDENTS HAVE ADDITIONAL PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, Virginia, or other state with a consumer privacy law, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

Sources of Personal Information

Learn more about the sources of personal information we collect in the section, “WHAT INFORMATION DO WE COLLECT?”

How We Use Personal Information

Learn more about how we use your personal information in the section, “HOW DO WE PROCESS YOUR INFORMATION?”

How We Sell or Share Personal Information

We sell or share the following categories of personal information for targeted advertising purposes:

• Identifiers
• Inferences drawn from collected personal information
• Internet or other similar network activity

Learn how to opt out of behavioral advertising in the US, please visit www.aboutads.info/choices and www.networkadvertising.org/choices.

We may share Newsletter Subscriber data with third-party data enhancement services to append demographic and interest information for advertising targeting purposes.

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

Learn more about how we disclose personal information in the section, “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

How Long We Retain Personal Information

Learn more about how long we retain personal information in the section, “HOW LONG DO WE KEEP YOUR INFORMATION?”

Your Rights

You have rights under certain US state privacy laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed
• Right to obtain a list of the categories of third parties to which we have disclosed personal data
• Right to obtain a list of specific third parties to which we have disclosed personal data
• Right to review, understand, question, and correct how personal data has been profiled
• Right to limit use and disclosure of sensitive personal data
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature

How to Exercise Your Rights

To exercise these rights, you can visit Your Privacy Choices, email us at privacy@paved.com or contact us using the contact details at the bottom of this document.

Under certain US state privacy laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state privacy laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@paved.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?”

11. WHAT CONTROLS DO WE HAVE FOR DO-NOT-TRACK AND GLOBAL PRIVACY CONTROL SIGNALS?

In Short: We do not currently respond to DNT browser signals but do honor GPC browser signals.

Do-Not-Track (DNT)

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals. California law requires us to let you know how we respond to web browser DNT signals. Because there is currently no industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

Global Privacy Control (GPC)

To manage cookies related to browser-based requests to www.paved.com, you can make your preference known using the Global Privacy Control ("GPC") signal. Requests sent using the Global Privacy Control will apply to the referenced website that you visit on the device and/or browser from which they are submitted. For more information about the Global Privacy Control, please visit www.globalprivacycontrol.org.

12. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

In Short: Yes, we will update this policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by an updated date at the top of this Privacy Policy. If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Policy frequently to be informed of how we are protecting your information.

13. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

If you have questions or comments about this policy, you may contact us by email at privacy@paved.com or contact us by mail at: